Plaintiff complains of defendant and says that heretofore to-wit: January 13”
1906 plaintiff and defendant were married to each other in Washington, Indiana.
That within six (6) weeks after said marriage, defendant without cause
abandoned plaintiff, and came to the city of Shelbyville, Indiana; that on the 9”
day of June, 1906, plaintiff came to Shelbyville, Indiana, where she met
defendant and that on the following day, June 10” 1906 defendant again
abandoned plaintiff without cause and they have ever since said date lived
separate and apart and are now living separate and apart at the time of the
filing of this complaint.
That during all of said marriage defendant has wholly failed, neglected and
refused to make any provisions whatever toward the support and maintainance of
this plaintiff although he is an able bodied man and amply able so to do.
That plaintiff during all of said time has been compelled to work out among
her neighbors and friends to earn a livelihood.
That during all of said marriage said defendant has continually sought the
society of and kept company with divers women, whose names to plaintiff are
unknown.
That defendant during said marriage has committed adultery with divers women
in the city of Washington, Indiana, and in the city of Shelbyville, Indiana, the
exact places, dates, occasions and names of which women, plaintiff cannot now
more particularly give. That the plaintiff at the time of said last separation
was wholly without means and was compelled to work out in the city of
Shelbyville, Indiana, for her own support and maintainance and is now at this
time working at the Ross House in said city.
That from the above and foregoing it will be impossible for plaintiff and
defendant to ever again live together as husband and wife.
WHEREFORE, Plaintiff prays the Court for a divorce and for all other further
proper relief. Tindall & Tindall Attorneys for Plaintiff